In Brief
The Revenue appealed the quashing of tax assessments made under Income Tax Act Section 153C for Assessment Years 2000-01 to 2003-04. The assessee Sinhgad Technical Education Society, a registered charitable trust, had its trust status cancelled and was reassessed as an association of persons following a search on its trustee that allegedly revealed capitation fees collection. The Supreme Court held that Section 153C requires that seized documents must pertain to the specific Assessment Years under examination—a mandatory jurisdictional requirement. Since the seized material belonged to Assessment Year 2004-05 onwards, the assessments for the four earlier years were legally unsustainable. The Court dismissed the Revenue's appeals, clarifying that this technical ground did not affect substantive findings regarding the trust's lack of genuineness or other Assessment Years' assessments.">
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